MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge.
This is a proceeding commenced under section 6015, based on respondent's determination that petitioner is not entitled to relief from joint and several liability for 1987, 1992, and 1995 with respect to joint returns filed with Hugh V. Smith, Jr. (H. Smith). Petitioner has now conceded that she is not entitled to relief for 1995 because she was not a party to a joint return for that year. Unless otherwise...
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